Privacy Policy & Cookies

1. This is the Privacy Policy of .... Radio Free Marseille Online, a Smarter Website.
The policy only applies to the websites created by Smarter Websites and not to the websites of other companies, individuals or organisations to which we provide links.
We respect the privacy of our visitors.

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website and otherwise in our dealings with you, including any data you may provide through this website. This website is not intended for children and we do not knowingly collect data relating to children.

Smarter Websites. is the controller of and responsible for your personal data (collectively referred to as “Smarter Websites“, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Our Contact details are:
Full name of legal entity: Smarter Websites.
Name of DPO: Marc Tracy
Email address: dpo @ smarterwebsites.net
Postal address: 27 Sherriff Close, Esher, Surrey. KT10 8AT. UK.
Telephone number: 07940 172 568

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( https://ico.org.uk/ ). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance. This version was last updated on 20-01-2019.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes name, job title and company name (if company purchase).
Contact Data includes company address (if company purchase) or residential billing and delivery address (if consumer purchase), email address.
Transaction Data includes details about payments to and from you and other details of purchases.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your identifying customer number, purchases or orders made by you.
Usage Data includes information about how you use our website and our information.

3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact, Correspondence and Financial Data by filling in forms on the website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you wish to communicate with us or create an account on our website.
Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, and other similar technologies. Technical Data from analytics providers such as Google based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.

4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract/agreement we are about to enter into or have entered into with you (i.e. where you wish to buy our products).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

5. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about cookies please see below.

6. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Disclosures of your personal data
We do not sell your personal data to third parties.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).

9. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data:
see Request erasure below for further information
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact our DPO on dpo @ smarterwebsites.net No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products to you. We will advise you if this is the case at the time you withdraw your consent.

Cookies:
What are cookies?
Cookies are tiny text files which are downloaded onto your computer, tablet or mobile phone via your browser when you visit a website. They enable specific details about your visit to our website to be recorded, retrieved and analysed by our site during subsequent visits or by other sites that recognise the cookie.
Cookies are essential to the effective operation of our website and if you are a subscriber of our services for you to view the members’ only content. Cookies on this site also help to tailor the products and services offered and advertised to our customers, both on this website and elsewhere.

Cookies can’t harm your computer and they don’t identify individual users.

We’re giving you this information as part of our initiative to comply with recent legislation, and to make sure we’re honest and clear about your privacy when using our website and our services.
We monitor developments in privacy and cookie-related best practice closely and if we think changes to our policy would be of benefit to you we’ll make a change to our policy.